2024-cv-09048

COMPLAINT filed by TV Tokyo Corporation; Jury Demand. Filing fee $ 405, receipt number AILNDC-22530167.

Exhibit 1

(Exhibit 2)

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Michael A. Hierl

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by William Benjamin Kalbac

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by Robert Payton Mcmurray

ATTORNEY Appearance for Plaintiff TV Tokyo Corporation by John Wilson

MOTION by Plaintiff TV Tokyo Corporation to seal document Plaintiff's Motion for Leave to File Under Seal

SEALED DOCUMENT by Plaintiff TV Tokyo Corporation Sealed Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by TV Tokyo Corporation

CASE ASSIGNED to the Honorable Steven C. Seeger. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (Civil Category 2).

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MINUTE entry before the Honorable Steven C. Seeger: An initial status report is due by December 11, 2024. Counsel must read the Standing Order entitled "Initial Status Conferences and Joint Initial Status Reports" on the Court's website. The parties must confer as required by Rule 26(f) about the nature, scope, and duration of discovery. The parties must submit two documents to the Court. First, the parties must file the Joint Initial Status Report under Rule 26(f) on the docket. A Word version of the Joint Initial Status Report is available on the Court's website. All parties must participate in the preparation and filing of the Joint Initial Status Report. The Court requires a joint report, so a filing by one side or the other is not sufficient. Second, the parties must email a Word version of a proposed Scheduling Order under Rule 16(b) to the Court's proposed order inbox. Lead counsel for the parties must participate in filing the initial status report. Plaintiff must serve this Order on all other parties. If the defendant has not been served with process, plaintiff's counsel must contact the Courtroom Deputy at jessica_j_ramos@ilnd.uscourts.gov to reschedule the initial status report deadline. Plaintiff should not file the Joint Initial Status Report before the defendant(s) has been served with process. The parties must discuss settlement in good faith and make a serious attempt to resolve this case amicably. All counsel of record must read and comply with this Court's Standing Orders on its webpage. Please pay special attention to the Standing Orders about Depositions and Discovery. Mailed notice.

MAILED Trademark report to Patent Trademark Office, Alexandria VA.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for leave to file under seal (Dckt. No. 7) is hereby denied for the reasons stated by the Court in Zorro Productions, Inc. v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (23-cv-5761). Mailed notice.

MOTION by Plaintiff TV Tokyo Corporation Plaintiff's Motion for Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MOTION by Plaintiff TV Tokyo Corporation to expedite Plaintiff's Motion for Expedited Discovery

STATUS Report Initial Status Report by TV Tokyo Corporation

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Honorable Virginia M. Kendall on 12/27/2024: Mailed notice.

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for electronic service of process under Rule 4(f)(3) (Dckt. No. 13) is hereby granted. Plaintiff's motion for expedited discovery (Dckt. No. 14) is hereby granted. Plaintiff must file a status report or a motion for default by April 25, 2025. Mailed notice.

SUMMONS Issued (Court Participant) as to Defendant ALIEX PREESS B051 Store and all other Defendants identified in the Complaint

STATUS Report by TV Tokyo Corporation

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the April 25, 2025 status report (Dckt. No. 20). Plaintiff notes that, as of April 25, 2025, none of the third-party e-commerce platforms have responded to Plaintiff's discovery requests. The docket does not reveal when Plaintiff served those discovery requests on the third parties, so the Court is unsure whether the third parties have exceeded the 14 days the Court permitted them to respond. In any case, the Court expects Plaintiff to keep this case moving. Plaintiff must file a status report by May 9, 2025. Plaintiff must serve Defendants or file a motion to compel discovery from the third-party e-commerce platforms by May 15, 2025. The Court directs the parties to engage in meaningful, good faith settlement discussions at the earliest opportunity. A failure to comply will lead to dismissal. Mailed notice

STATUS Report by TV Tokyo Corporation

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed the status report. (Dckt. No. 22) The Court expects Plaintiff to move this case forward in an expeditious manner. The Court reaffirms the deadline of May 15, 2025 to file a status report or a motion to compel. The Court directs the parties to engage in good faith, energetic settlement discussions. Plaintiff must press the case forward in a diligent manner, with a sense of purpose. Plaintiff must serve a copy of this order and file a certificate of service. Mailed notice

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of TV Tokyo Corporation

NOTICE of Voluntary Dismissal by TV Tokyo Corporation Plaintiff's Notice of Voluntary Dismissal as to Certain Defendants

STATUS Report by TV Tokyo Corporation

SUMMONS Returned Executed by TV Tokyo Corporation as to The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto on 5/15/2025, answer due 6/5/2025.

MINUTE entry before the Honorable Steven C. Seeger: Based on the affidavit of service (Dckt. No. 27), the answers are due by June 5, 2025. If Defendants do not meet that deadline, then Plaintiff must file a motion for the entry of default and default judgment by June 6, 2025 (not June 9, as Plaintiff proposed). A response to that motion is due by June 20, 2025. The Court reminds Plaintiff to submit a Word version of the proposed judgment to the proposed order inbox, proposed_order_seeger@ilnd.uscourts.gov. A failure to comply will lead to appropriate relief, including dismissal or the entry of judgment. Plaintiff must serve a copy of this order and file a certificate of service. Mailed notice

CERTIFICATE of Service by Robert Payton Mcmurray on behalf of TV Tokyo Corporation

MOTION by Plaintiff TV Tokyo Corporation for default judgment as to Plaintiff's Motion for Entry of Default and Default Judgment Against Defendants Identified on Amended Schedule A

(Exhibit A)

MEMORANDUM by TV Tokyo Corporation in support of motion for default judgment 30

Exhibit 1

(Exhibit 2)

DECLARATION of Michael A. Hierl regarding motion for default judgment 30

(Exhibit Hierl Exhibit 1)

MINUTE entry before the Honorable Steven C. Seeger: The Court reviewed Plaintiff's motion for default and default judgment (Dckt. No. 30). The answer deadline of June 5, 2025 (Dckt. No. 27) has come and gone, and Defendants did not respond to the complaint. The Court hereby enters default against all remaining Defendants under Rule 55(a). As a reminder, any response to Plaintiff's motion for default judgment is due by June 20, 2025 (Dckt. No. 28). A failure to comply will lead to appropriate relief, including possible entry of judgment. The Court reminds Plaintiff of the need to submit a Word version of a proposed judgment to the proposed order inbox, Proposed_Order_Seeger@ ilnd.uscourts.gov. Plaintiff must serve a copy of this order on Defendants and file a certificate of service. Emailed notice

CERTIFICATE of Service by William Benjamin Kalbac on behalf of TV Tokyo Corporation

MINUTE entry before the Honorable Steven C. Seeger: Plaintiff's motion for the entry of default judgment (Dckt. No. 30) against all remaining Defendants on the Amended Schedule A is hereby granted. Any answer to the complaint from Defendants was due by June 5, 2025. That date has come and gone. On June 17, 2025, the Court entered default against all remaining Defendants under Rule 55(a) (Dckt. No. 33). The Court also previously set a deadline of June 20, 2025 (Dckt. No. 28) for any Defendant to respond to the motion for default and default judgment. No Defendant responded to that motion, and that date has now passed. So the motion for default judgment against the remaining Defendants (Dckt. No. 30) is hereby granted. The Court enters default judgment against all Defendants on the Amended Schedule A under Rule 55(b). Final Judgment Order and Permanent Injunction Order to follow. The case is closed. Civil case terminated. Mailed notice.

PERMANENT INJUNCTION ORDER Signed by the Honorable Steven C. Seeger on 6/24/2025. Mailed notice.

FINAL JUDGMENT ORDER Signed by the Honorable Steven C. Seeger on 6/24/2025. Mailed notice.